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Reply to BC Groups from MoE on Sludge Spreading |
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Robert Wiltzen and Co-Signors
Crofton Airshed Citizens Group
Dear Mr. Wiltzen and Co-Signors:
Thank you for your email dated September 14, 2007 to the Honourable
Barry Penner, Minister of Environment, regarding the Code of Practice
for Soil Amendments (the Code). Your email has been forwarded to me to
respond on the Minister's behalf.
See the Reply to This Letter from BC Groups/
The practice of using industrial residuals to enhance soil quality is
neither new nor unique to British Columbia. All jurisdictions in North
America and Europe have rules or regulations governing how agricultural,
industrial, and municipal residuals may be used on land. British
Columbia's Code uses a multi-layered approach to protect human health
and the environment. The more salient features of the Code include:
1. A limited list of materials that can be applied: Unlike some
jurisdictions, the Code only allows the use of specific materials for
which we have data and a scientific track record of beneficial
application to land. Only a select number of materials fit this
criterion.
2. Maximum contaminant levels: Consistent with the Organic Matter
Recycling Regulation (OMRR), the Code uses the same quality parameters
and maximum levels as for Class A municipal biosolids which are
harmonized with the federal Fertilizers Act.
3. Notice to Ministry of Environment Regional Managers, Medical
Health Officers and the Agricultural Land Commission: Under the Code,
these three offices would have the ability to impose additional
requirements or even prohibit any individual land application if they
see a need to do so. In addition, the Waste Discharge Regulation allows
the director to impose additional requirements through the use of a
substitution.
4. Land Application Plans: The Code prohibits application of waste
in quantities that would exceed the nutrient needs of the plants at the
application site. A qualified professional must prepare a land
application plan. In the land application plan, the qualified
professional must predict the expected concentration of constituents in
the soil, and calculate the amount of soil amendment that can be applied
to provide for the plant or crop needs.
5. Steps to ensure soil is enhanced: The discharger is responsible
for ensuring that the application of a soil amendment to land has a
positive effect on the soil. They must analyse the soil and the soil
amendment, and then have a qualified professional calculate the
predicted concentration of contaminants in the soil after land
application. The calculated level in the soil must stay below
contaminated site criteria levels.
6. Cannot cause pollution: The final level of protection for any
discharge of waste under a code of practice is the absolute prohibition
against causing pollution as found in Section 6(4) of the Environmental
Management Act. This section prevents a person from introducing waste
into the environment in a manner or quantity that would cause pollution.
If pollution is being caused, a director may issue an order to address
the environmental concerns.
As for specific monitoring and other requirements, the Code requires the
following:
1. An initial analysis of the soil amendment for the contaminants
listed in the code;
2. Ongoing monitoring of the soil amendments, either for every
1,000 tonnes of pulp mill biosolids applied, or annually, whichever is
earlier, and the director may require more frequent monitoring if
necessary;
3. Analysis of the soil at the land application site to determine
baseline levels of contaminants;
4. A prediction of the soil concentrations of contaminants based on
application rates listed in the land application plan; and
5. Certification from the qualified professional that the soil
amendment was applied to the land in accordance with the land
application plan.
The Code is designed to provide consistent protection to human health
and the environment. Based on the best available scientific information,
we have also incorporated multiple layers of protection. We will
continue to monitor and recommend changes, if, and when, new information
indicates a need.
Thank you for your concern for our environment.
Yours truly,
Lynn Bailey
Assistant Deputy Minister
Environmental Protection Division
pc: Honourable Barry Penner, Minister of Environment
See the Reply to This Letter from BC Groups/
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